SANKO Privacy Policy

1. Data Controller

PJM Sanko Ltd, registered in England and Wales, is the data controller responsible for your personal data under applicable data protection laws, including the UK GDPR and EU GDPR where applicable.

2. Data We Collect

We may collect the following categories of personal data:

• Identity Data: name, date of birth, gender, profile information.
• Contact Data: address, email address, telephone number.
• Transaction Data: payment details, order history, escrow transactions.
• Technical Data: IP address, device information, browser type, cookies.
• Usage Data: how you interact with the Platform, preferences, feedback.
• Marketing Data: communication preferences and engagement with campaigns.

3. How We Use Your Data

We use personal data for the following purposes:

• 3.1 To provide, operate, and improve the Platform.
• 3.2 To process transactions and manage the escrow system.
• 3.3 To communicate with Buyers and Sellers regarding orders, disputes, and support.
• 3.4 To personalise content, marketing, and recommendations.
• 3.5 To comply with legal, regulatory, and tax obligations.
• 3.6 To protect against fraud, misuse, or unauthorised activity.

4. Legal Basis for Processing

We rely on the following lawful bases under the GDPR:

• Contract: where processing is necessary to perform our obligations under the Buyer Terms of Service or Seller Agreement.
• Legal obligation: where processing is required to comply with applicable laws.
• Legitimate interests: where processing supports the safe and effective operation of the Platform.
• Consent: where you have provided consent (e.g. for marketing communications).

5. Sharing of Data

We may share your data with:

• Sellers (for fulfilment of Buyer orders).
• Buyers (for confirmation of Seller transactions).
• Third-party service providers (including payment processors, couriers, IT, and support services).
• Regulators, courts, or authorities where required by law.

We do not sell personal data to third parties.

6. International Transfers

As Sanko operates globally, personal data may be transferred outside the UK or EU. Where this occurs, we ensure adequate safeguards are in place, including Standard Contractual Clauses approved by the European Commission or UK Information Commissioner's Office.

7. Data Retention

We retain personal data only as long as necessary to:

• Fulfil the purposes described in this Policy,
• Comply with legal and regulatory obligations,
• Resolve disputes and enforce agreements.

8. Data Security

We use technical and organisational measures to protect data, including encryption, access controls, and secure payment processing. While we take all reasonable steps, no system can guarantee absolute security.

9. Your Rights

Under data protection laws, you have the following rights:

• Access to your personal data.
• Correction of inaccurate or incomplete data.
• Deletion of data where no longer necessary ("right to be forgotten").
• Restriction of processing in certain circumstances.
• Data portability.
• Objection to processing based on legitimate interests or direct marketing.
• Withdrawal of consent where consent has been given.

Requests can be submitted by contacting us at privacy@pjmsanko.com.

10. Cookies

The Platform uses cookies and similar technologies to improve functionality, personalise content, and analyse usage. For further details, please see our separate Cookie Policy.

11. Changes to this Policy

We may update this Policy from time to time. Significant changes will be communicated through the Platform or by direct notice.

12. Contact Us

If you have any questions about this Policy or how your data is handled, please contact: